Why you should read this document

During the course of providing financial advice and services, Prosperity Medical Financial Services LLP (“we”, “us”, “our”) will need to collect and use personal information about you. This Privacy Notice explains what information we collect, how it is used, who it is shared with and the rights you have under data protection law.

What we mean by “Personal Data”

Personal data means any information that identifies you or relates to your personal circumstances. This includes information such as your name, address, date of birth, National Insurance number, financial position, employment details and, where relevant, information about your health or family circumstances.

Personal data we collect

We collect personal data from you directly, and sometimes from third parties such as product providers, credit reference agencies, fraud prevention agencies and public sources. This may include:

• Name, address, email address and telephone numbers
• Date of birth and identification details
• Family and household circumstances
• Financial and employment information
• Details of products and services you hold
• Credit, fraud and anti-money-laundering information

We will tell you if providing any information is optional.

Our legal basis for processing your data

We process your personal data under the following lawful bases:

• Contract – to provide financial advice and services and to arrange and manage the products you request
• Legal obligation – to comply with FCA rules, anti-money-laundering laws, record-keeping and complaints-handling requirements
• Legitimate interests – to manage our business, deal with queries, obtain professional advice and improve our services
• Substantial public interest – where we process health or insurance-related information

We do not rely on consent as the legal basis for providing regulated financial services.

Special category data

Where you apply for insurance or certain financial products, we may process special category data such as health information, medical history or (where required by insurers) ethnic origin or criminal convictions. This is necessary for underwriting, claims, fraud prevention and regulatory compliance.

How your data is stored and used

We may record and store your personal data in:

• Paper files
• Secure IT systems and email, and
• Secure cloud-based systems

Access is restricted to authorised staff and professional advisers where necessary to provide our services.

Who we share your data with

We may share your data with:

• Investment, pension, mortgage, finance and insurance providers
• Our compliance advisers, IT providers and professional advisers
• Credit reference and fraud prevention agencies
• The Financial Conduct Authority and other regulators
• Courts or law-enforcement where required

Your data is only shared where necessary to provide our services or to meet legal or regulatory obligations.

International transfers

Where any personal data is processed outside the UK or EEA, appropriate safeguards will be in place in line with UK GDPR requirements.

How long we keep your data

We normally retain client records for at least six years, and longer where required for regulatory, legal or tax purposes.

Your rights

You have the right to:

• Access your personal data
• Correct inaccurate data
• Restrict or object to processing
• Request erasure (where legally permitted)
• Data portability
• Complain to the Information Commissioner’s Office (ICO)

Contact

Prosperity Medical Financial Services LLP
Data Protection Contact: Martin Cleaver

If you have any concerns about how your data is used, please contact us in the first instance.